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NIOSH Response to “SC&A Review [April 

2023] of NIOSH Response [January 2023] 

to SC&A’s Supplemental Review of M&C 

Work Group Issues [August 2022]”

Response Paper

National Institute for Occupational

Safety and Health

August 22, 2023 

Pat McCloskey, CHP, CIH 

Mutty Sharfi, CHP, CIH 

Nick Bailey

Oak Ridge Associated Universities Team

Reviewed by

Brant Ulsh, Ph.D., CHP 

LaVon Rutherford, CHP 

Timothy Taulbee, Ph.D., CHP

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 2 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

INTRODUCTION

Since NIOSH completed the Special Exposure Cohort (SEC)-00236 Evaluation Report in 2017 

[NIOSH 2017], NIOSH, SC&A, and the Advisory Board on Radiation and Worker Health, 

including members of the Metals and Control (M&C) Work Group, have conducted numerous 

follow-on discussions, meetings, and technical assessments regarding topics of interest identified

by SC&A and Advisory Board members. This response paper addresses the most recent SC&A 

review in a series of response papers between SC&A and NIOSH, starting with SC&A’s 

Supplemental Review of M&C Work Group Issues [SC&A 2022]. 

• On August 22, 2022, NIOSH received SC&A’s Supplemental Review of M&C Work 

Group Issues [SC&A 2022].

• On January 13, 2023, NIOSH issued its response, NIOSH Response to SC&A’s 

Supplemental Review of M&C Work Group Issues [NIOSH 2023], to SC&A’s August 

2022 supplemental review. 

• On April 25, 2023, NIOSH received SC&A’s response, SC&A Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work Group Issues [SC&A 2023], to 

NIOSH’s January 2023 review. 

This NIOSH response paper addresses M&C Work Group concerns about NIOSH’s ability to 

bound doses associated with (1) the effects of a coagulant on the source term, (2) the 

aerosolization of drain line contamination, and (3) work in confined spaces. Below, NIOSH 

presents the concerns that SC&A identified in their latest response, SC&A Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work Group Issues [SC&A 2023] as new or 

not addressed and follows each with a response. Beyond responding to SC&A’s latest review, as 

agreed during the May 12, 2023, M&C Work Group meeting, NIOSH has provided additional 

information concerning intrusive activities and dose potential that can be used to augment Table 

1 in SC&A’s Supplemental Review of M&C Work Group Issues [SC&A 2022, PDF p. 16]. 

Additionally, NIOSH has responded to M&C Work Group concerns raised during recent 

meetings, including concerns identified in the M&C Work Group presentation at the August 16, 

2023 Advisory Board on Radiation and Worker Health meeting. 

Note: NIOSH has added bold text throughout this document to show emphasis. 

EFFECTS OF COAGULANT ON SOURCE TERM

SC&A Comment – Atomic Weapons Employer (AWE)-Related Coagulants in Drain Lines 

The release of nonradioactive coagulant oil to drain lines was done separately from any 

HFIR operational radioactive releases and may have had a collateral influence on how 

AWE-related uranium and thorium contamination already in the piping would have 

concentrated over the years following those original discharges. In fact, in its response, 

NIOSH supports this interpretation by making the case that “wire operations during the 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

residual period did not process radioactive materials; therefore, most material rinsed 

into the drains was non-radioactive except for residual contamination that remained in 

cracks and crevices” (NIOSH 2023, p. 12). SC&A agrees with NIOSH that the wiring 

operations did not contribute radioactive materials to the drain lines. It was the 

coagulant oil itself that may have consolidated the uranium and thorium already 

entrained in the pipes (“cracks and crevices”) that would have impacted the covered 

AWE material from prior years (the resulting sediment would not have been 

distinguishable between AWE and HFIR residual contamination). [SC&A 2023, PDF pp. 

7–8]

NIOSH Response – AWE-Related Coagulants in Drain Lines 

There appears to be a misinterpretation of the following NIOSH statement: 

More specifically, wire operations during the residual period did not process radioactive 

materials; therefore, most material rinsed into the drains was non-radioactive except for 

residual contamination that remained in cracks and crevices, as shown in the following 

figures. [NIOSH 2023, PDF p. 17]

Although it is still possible that there were cracks and crevices within the drain lines as SC&A 

describes, NIOSH refers to the low-level contamination that remained in the cracks and crevices 

under the wire machines, as shown on the subsequent pages in Figures 1 and 2 of NIOSH [2023, 

PDF pp. 18–19]. 

SC&A Comment – Coagulant Concentrations and Maintenance Workers

The AWE sediment was clearly present within the system following the cessation of AWE 

operations; any later introduction of oil-based coagulant solutions within that system 

may have collected and concentrated the uranium and thorium already present in that 

system and led to higher sedimentation to which M&C maintenance workers would have 

been exposed. This concern represents a new issue that has not been addressed. [SC&A 

2023, PDF p. 8]

NIOSH Response – Coagulant Concentrations and Maintenance Workers

The following excerpts from an interview with a [redacted] that worked from [redacted] provide 

some insight into M&C’s issues with coagulant: 

Mr. McCloskey: Let’s go back to those roof drains. We understand that those drains that 

came down from roof were, for the most part, cast iron. 

Worker #7: Yes, for the most part they were cast. They went out to Building 11. They 

were routed out there. There was a pond out there. Do you know how I know that? The 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Wiredrawing line with the wire mill had that green lube in it. The motors were in a pit in 

the floor. They asked, “What are we going to do about the rainwater? Well, when we 

have a flood, we’ll just pump it into roof drain and let it go out with the clean water.” 

They had a malfunction in the wiredrawing machine, and it filled that up with green lube. 

I came in one morning and the pond was green. The fountain was green. [Redacted] was 

the VP at the time, so I had to go tell him that the pond was green. [ORAUT 2017, PDF 

pp. 12–13]

Mr. McCloskey: This photo shows where they took out the concrete floor in Building 10. 

This might have more meaning for you. This photo is of the Priority One Drains that 

were underneath the ground right in this area. 

Worker #7: This is where the M125 was. There was a big tank in the ground here. 

Mr. McCloskey: How deep was it into the ground? Was that the 6-foot by 6-foot tank? 

Worker #7: No, that was a big tank. They used that for the Wire Drawing. This tank was 

already here for the M125. What happened was, instead of putting another tank in that 

had the capacity for both machines, we dug a trench through here, and behind Building 

10 to pipe this all the way over to the Beckett Line. That’s where they mixed the green 

goop. [ORAUT 2017, PDF p. 17–18]

Although these excerpts do not directly address SC&A’s concern, they do reveal that this 

maintenance supervisor may know additional details worth pursuing. In addition, this worker 

also indicated the Beckett (aka Beckhart) line was installed in 1983–84, which is after all 

radioactive work ceased. This machine was a major source of coagulants to Area 9 drain lines in 

Building 10; therefore, NIOSH may ask this worker follow-up questions to ensure appropriate 

details are incorporated into the M&C Technical Basis Document (TBD). 

As part of incorporating concerns related to the presence of coagulants in drain lines into the 

TBD, NIOSH will:

• Identify the locations of wire machines in Building 10 and overlay their locations above 

the drain lines to indicate their distance from Priority 1 drain lines. 

• Mark-up the drain lines with flow paths to determine which lines were downstream of the 

coagulant sources (i.e., wire machines). 

The drainage system consisted of 4-inch floor drains and feeder lines at various locations above 

the subsurface drainage system. They flowed to 4-inch vitreous clay (VC) and 4-, 5-, and 6-inch 

cast iron (CI) lines (referred to as arterial lines) located 2 to 3 feet below facility grade. These 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

arterial lines typically ran from north to south or south to north, and usually flowed into eastwest lines of 6 to 12 inches in diameter (referred to as main lines). Main lines were routed to a 

lift station, followed by discharge into a stream channel running from the facility [Weston 1996a, 

PDF p. 168]. 

NIOSH will also consider the following: 

• Weston could have noted and collected coagulant when they characterized the drain lines, 

as described in the following. “After pipes were opened, a sample of the sediment or 

other residue in the pipe was collected and submitted for isotopic and/or total uranium 

analyses” [Weston 1996b, PDF p. 11]. For example, the clay pipe with the highest 

interior surface contamination (1,000,000 disintegrations per minute [dpm]/100 cm2) “did 

not contain a visible accumulation of residue” [Weston 1996b, PDF p. 11]. 

• The airborne hazard associated with cleaning clogged pipes was minimal because the 

material was wet, and the presence of coagulants functioned as glue, effectively 

locking/fixing contamination in place along the pipe’s interior surfaces. These conditions 

significantly reduced the resuspension and respirability of the source term, eliminating 

the coagulant concern from consideration as a bounding internal dose scenario for 

NIOSH to incorporate. The fixed contamination could be an external contributor that 

NIOSH’s external dose model will address. NIOSH requests SC&A to supply a technical 

justification showing that a coagulant can function as both a substance that is sticky 

enough to clog drains and allow resuspension of respirable particles. 

• NIOSH's experience with surface contamination indicates it would either travel through 

and exit the system or become fixed such that an aggressive decontamination technique 

would be required to move it through the system. NIOSH performed a literature search to 

confirm SC&A’s assertion and studied vegetable/mineral oils to determine their physical 

properties (e.g., pH) to see if they possessed solvent properties sufficient to mobilize a 

fixed contaminant and accumulate it downstream. NIOSH did not find any supporting 

information in the technical literature. If SC&A is aware of such information, NIOSH 

will consider it.

Using the best science available to generate its models, NIOSH has determined that it can

describe plausibly, and bound exposures associated with unclogging pipes while accounting for 

the effects of introducing a nonradioactive coagulant to the drain line source term.
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

AEROSOLIZATION OF DRAIN LINE CONTAMINATION (1,000,000 dpm/100 cm2) 

SC&A Comment – Cleaning/Cutting Drain Lines 

Another historical aspect of M&C drain lines is the accumulation of contaminant scale 

that has plated out inside the piping. This scaling was found in at least one instance at 

M&C to exceed 1,000,000 dpm/100 cm2 in a 4-inch mainline drain that was being cut 

and removed (NIOSH, 2021a, p. 7). While such pipe scale has been identified at other 

AWE sites, M&C maintenance workers frequently cut, repaired, replaced, and cleaned 

out such piping during the residual years using power tools such as saws, drills, 

grinders, and powered snakes, as well as cutting torches. [SC&A 2022, PDF p. 22] 

NIOSH Response – Cleaning/Cutting Drain Lines

SC&A begins the paragraph above discussing drain lines, which NIOSH and SC&A agree 

represent the most significant source term. 

Regarding the following SC&A excerpt from above: 

M&C maintenance workers frequently cut, repaired, replaced, and cleaned out such 

piping during the residual years using power tools such as saws, drills, grinders, and 

powered snakes, as well as cutting torches.

The drain lines of concern were either cast iron or clay and would have been cut with a snapcutter or saw and not routinely cut with torches. There were other services that traversed the 

subsurface (e.g., airlines, recirculation piping); however, NIOSH does not consider work 

performed in the subsurface at a distance (>5 ft) from the drain lines to represent the bounding 

scenario. This is discussed below under the “NIOSH Response – Confined Spaces and Work Not 

Associated with Drain Line Cleaning” heading. 

SC&A Comment – Bridgeport Brass Hazard Assessment (Torch Cutting)

...As noted by DOE in its hazard assessment of the Bridgeport Brass AWE, “the residual 

uranium could eventually be released . . . through intrusive work activities such as pipe 

cutting and removal” (DOE, 1996, PDF p. 11), and that “it is possible that under certain

conditions (such as cutting through a steel pipe with a cutting torch) surface activity 

attached to the steel could be released with the steel particles” (DOE, 1996, PDF p. 48). 

[SC&A 2022, PDF p. 22] 

NIOSH Response – Bridgeport Brass Hazard Assessment (Torch Cutting)

The excerpt above shows why the reference provided by SC&A is concerned with the torch 

cutting of drain lines, and since M&C’s drain lines were not steel, NIOSH did not select torch 

cutting of drain lines as a bounding scenario.
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 7 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH reviewed the U.S. Department of Energy (DOE) Bridgeport Brass AWE Hazard 

Assessment [DOE 1996] referenced by SC&A to determine the types of pipes that were cut with 

torches and found the following: 

Many of the drain lines at the GM site are constructed of carbon steel. It is unlikely that 

contamination could penetrate uniformly as deep as 1 cm into carbon steel (or even clay 

tile pipes). [DOE 1996, PDF p. 47] 

SC&A Comment – Bridgeport Brass Hazard Assessment (Pipe Cutting)

NIOSH fails to address the source of this concern: the U.S. Department of Energy’s 

(DOE’s) Bridgeport Brass AWE hazard assessment, where it was warned that pipe 

cutting involving internal radioactive contamination could lead to airborne releases that 

may involve worker exposure (DOE, 1996, PDF p. 48). [SC&A 2023, PDF p. 8] 

NIOSH Response – Bridgeport Brass Hazard Assessment (Pipe Cutting)

NIOSH reviewed the complete Bridgeport Brass Hazard Assessment [DOE 1996] referenced by 

SC&A and found the following: 

• DOE assessed the potential exposure to residual uranium located in the extrusion press 

pits, the oil collection system (including manholes, sumps, and drain lines), and the 

former floor drains [PDF p. 32]. 

• The maximum U-238 concentration was reported as 21,000 pCi/g (Manhole 2) [PDF p. 

29] and a maximum surface contamination level of 1.3 million dpm/100cm2 (Drain Line 

C) [PDF p. 26].

• Routes of exposure for a maintenance worker included direct exposure to external gamma 

radiation, inhalation of contaminated dust, and ingesting contaminated material during 

intrusive work activities below the building floor [PDF p. 33]. 

• It was assumed that workers could be exposed through participation in large-scale 

renovation operations at the facility, including partial demolition of the building, removal 

of part of the floor, or removal of selected portions of the old underground drain system 

[PDF p. 33]. 

• Two job categories: non-routine maintenance worker and future renovation worker. The 

non-routine maintenance worker category assumes 23 working days per year and the 

renovation worker category assumes 71 [PDF p. 36]. 

• Mass loading was assumed to be 1E-4 g/m3 (100 μg/m3). The respirable fraction was 

assumed to be 30% [PDF p. 36]. 

• The estimated worst-case exposure calculated for maintenance workers was 30 

mrem/year. For renovation workers the dose estimate was 43 mrem/year [PDF p. 44]. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 8 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

• Respiratory protection was not considered in the dose estimates [PDF p. 49].

As shown in Table 1 below, the ratio of assigned dose to source term level using the Bridgeport 

Brass reference SC&A recommended compares favorably to that proposed for M&C. 

Table 1: Max Source Term and Annual Total Effective Dose for Bridgeport Brass and M&C

Site Max Source Term (pCi/g) Annual Total Effective Dose 

(mrem)

Bridgeport Brass 21,000 43

Metals and Controls 53,224 120

SC&A Comment – Systemic or Isolated Drain Line/Pipe Scale (1,000,000 dpm/100 cm2) 

NIOSH contends that cutting of drain lines with contaminated scale exceeding 1,000,000 

disintegrations per minute per 100 square centimeters (dpm/100 cm2) would constitute 

“isolated hot spots,” not a systemic condition, and that in any case, it does not believe 

there is any evidence that even higher activity levels might have existed. [SC&A 2023, 

PDF p. 8]

NIOSH Response – Systemic or Isolated Drain Line/Pipe Scale (1,000,000 dpm/100 cm2) 

SC&A’s line of inquiry about pipe scale stems from a misinterpretation of one survey indicating 

a contamination level of 1,000,000 dpm/100 cm2 found in the Screen Print Room (Area 7). The 

following is from SC&A’s Supplemental Review of M&C Work Group Issues: 

Another historical aspect of M&C drain lines is the accumulation of contaminant scale

that has plated out inside the piping. This scaling was found in at least one instance at 

M&C to exceed 1,000,000 dpm/100 cm2 in a 4-inch mainline drain that was being cut 

and removed (NIOSH, 2021a, p. 7). [SC&A 2022, PDF p. 22] 

The Weston [1996b] drainage system characterization does not identify any scale found at the 

location SC&A references [PDF pp. 10–11]. As NIOSH previously noted, this drain line was 

clay; scale/rust is associated with cast iron drain lines. To further clarify, this pipe had 

contamination levels as high as 1,000,000 dpm/100 cm2 and was cut and removed by Weston 

decontamination and decommissioning (D&D) workers, not as part of M&C maintenance work. 

SC&A Comment – Systemic or Isolated Drain Line/Pipe Scale (Additional Survey 

Evidence)

NIOSH presents no evidence that this contaminated scale would not have been present 

elsewhere in the piping system, could have involved both metal and clay pipes, or that 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 9 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

even higher activity levels may have been present elsewhere in the pipe network. [SC&A 

2023, PDF p. 8] 

NIOSH Response – Systemic or Isolated Drain Line/Pipe Scale (Additional Survey 

Evidence)

NIOSH relies on the available source-term survey data because of the comprehensiveness 

exercised by Weston and Texas Instruments as indicated in the following December 1994 

statement: 

The Tl Environmental Department, its consultants, and retained counsel performed a 

review of historical documents including reports, drawings, maps and photographs, 

previous radiological surveys, and interviewed selected employees who had knowledge of 

past nuclear operations in order to identify any open land areas and building interiors

that had the potential for residual contamination. Details of this review are contained in 

TI files. The results of this review are reflected in the supplemental survey design, 

Sections 3.0 to 7.0, as it influenced the selection of areas and methods for further study. 

[Texas Instruments 1994, PDF p. 29]

Regarding existing scale data, Weston executed intrusive drain line sampling according to their 

Sampling and Analysis Plan (SAP) submitted to the Nuclear Regulatory Commission (NRC) in 

July 1995. The SAP provided a method to identify contamination on the concrete floor and 

underlying soils within the 8000 ft2

 Building 10. In addition to the systematic sampling 

prescribed by NUREG/CR-5849, Weston collected biased samples at “cracks or other locations 

across the grid exhibiting elevated surface activity measurements” [Weston 1995, PDF p. 6]. 

Weston reported collecting scale samples at locations 2, 3, 4, and 5 [Weston 1996b, PDF pp. 15, 

17] that provide contamination data as high as 507.7 pCi/g [Weston 1996b, PDF p. 18]. In 

addition, NIOSH has the following information: 

• In the Caged Area (Areas 1 and 4 where the fuel rod was found), radiological surveys of 

this piping typically showed marginal surface contamination on the interiors of the pipes, 

typically ranging from less than 3000 dpm/100 cm2

 [Weston 1996b, PDF p. 10]. 

• Locations 4 and 5 accessed lines that had previously supported assay laboratories 

associated with nuclear material manufacturing activities. Sampling and visual 

observation confirmed that these lines had little to no residue accumulation. Analytical 

data for both CI lines showed a total uranium concentration of approximately 500 pCi/g 

in the thin layer of scale [Weston 1996b, PDF p. 17]. 

• Areas 3 and 4 were identified as having scale and rust with a total uranium concentration 

of 1,864 pCi/g [Weston 1996a, PDF p. 174]. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 10 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

In addition, NIOSH can use Weston [1996b] Table 3, Building 10 Feed Drain Surveys [PDF p. 

21], particularly the beta scintillator data as scale activity measurements, because Weston 

[1996b] states:

Prior to use of the 1-inch by 1-inch sodium iodide system, a Ludlum Model 44-1 beta 

scintillator/Model 2221 scaler/ratemeter was used in 8 to 10 feed lines. Although the 

geometry of this system is not optimal for detecting large accumulations in or around 

pipes, it is adequate for identifying contaminated scale within the line. [Weston 1996b, 

PDF p. 12]

M&C also developed a method to calculate surface contamination levels on pipe interiors using 

the thickness of residue lining the pipes and the total uranium concentration in the residue. Both 

parameters were determined using samples for representative sections of the drain lines. 

Sampling methodologies, frequencies, and locations are discussed in the 1997 Texas Instrument 

drainage supplemental analysis report (Appendix 1) [Weston 1997a, PDF p. 11]. Using the 

method described in Weston [1997a], additional data are available to NIOSH, including drain 

calculations with conversions to surface activity where total surface contamination levels prior to

decontamination ranged from 53,000 to 95,000 dpm/100 cm2

 [Weston 1997a, PDF pp. 13, 15].

In summary, neither SC&A nor the M&C Work Group has provided any evidence explaining 

why these surveys are not a suitable basis for NIOSH’s bounding source term. This issue boils 

down to a demand that NIOSH prove a negative (i.e., prove something did not exist). NIOSH has 

cited credible evidence to support its calculations. Assertions that there could have been other 

higher contamination levels—with no supporting evidence—rely on speculation. NIOSH’s 

model using the pre-D&D survey that included a fuel pin in the pipe is the highest plausible 

bounding scenario. NIOSH has not received any technical evidence contradicting the use of this

survey in a bounding model. 

SC&A Comment – Bounding Exposure Pathway

NIOSH’s reliance on “mass-based sample data” and “soil-sampling plans” does not 

address the simple question raised: Given that an AWE hazard assessment raised this 

general worker exposure concern, can this [1,000,000 dpm/100 cm2

] potential exposure 

pathway at M&C be characterized and bounded? This concern represents a new issue 

that has not been addressed. [SC&A 2023, PDF p. 8] 

NIOSH Response – Bounding Exposure Pathway

NIOSH used the source term concentration calculation from the Bridgeport Brass AWE Hazard 

Assessment [DOE 1996], recommended by SC&A, to calculate an inside subsurface dose that 

incorporates the million dpm survey value that can be used to model cutting through a 

contaminated pipe. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 11 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

DOE [1996, PDF p. 47] shows: 

pCi/g = (SC x CF)/(T x ρ)

where

SC = source concentration in dpm/cm2

CF = conversion factor of 0.45 pCi/dpm 

T = thickness of surface activity (cm)

ρ = density of contamination

using 

 1,000,000 dpm/100 cm2

 10,000 dpm/cm2

 0.45 pCi/dpm 

 0.1 cm

 1.5 g/cm3 (density) 

pCi/g = (10,000 x 0.45)/(0.1 x 1.5) 

This calculation shows that adding this one survey result to NIOSH’s other subsurface data will

increase maintenance worker dose from 71 to 96 mrem committed effective dose (CED).

This adjustment is based on only adding the single value (1,000,000 dpm/100 cm2) to NIOSH’s

dataset. According to Weston [1996b], this was the highest surface contamination value, and as 

shown above, additional data are available. Therefore, adding this single value biases the dataset 

in a very claimant-favorable way (i.e., it increased the 95th percentile by almost a factor of 2). 

NIOSH has determined that it has methods for incorporating surface contamination data into a 

bounding method, eliminating the aerosolization of drain line contamination as an SEC issue. 

WORK IN CONFINED SPACES

SC&A Comment – Routine Drain Line Repair in Pits or Trenches (Six Month Occupancy)

As emphasized in former worker interviews, it was not uncommon to be working in a trench 

doing routine utility repairs or pipe cleanouts for days and up to a week (NIOSH, 2017c, pp. 

1–2). One installation project in Building 10 involved the cutting out of an existing drain line 

and installation of new equipment, piping, and large tanks, necessitating a trench 100 feet 

long, with a depth of 8–10 feet in places, that was worked in for 6 months in 1983–1984 

(NIOSH, 2017d, p. 11). [SC&A 2023, PDF p. 9] 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 12 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response – Routine Drain Line Repair in Pits or Trenches (Six Month Occupancy)

There appears to be some misinterpretation in SC&A’s description of work performed in 

confined spaces that requires clarification. SC&A stated that M&C workers were performing 

confined space work for six months, presumably to install the Beckett line mentioned in the 

following interview excerpts from a [redacted] who worked from [redacted]: 

Mr. McCloskey: If someone needed to cut into the floor, was there attention given to it by 

Health and Safety people who would evaluate the work that you were going to do—to say 

we need to think about the dust you’re going to create when you cut the concrete? 

Worker #7: No. The only time we used to call Health and Safety was for confined space 

entries. They would have to do air sampling because we had a lot of trichloroethylene in 

the early days, and that’s heavier than air. So, if there was a pit—some of the slitting 

equipment had pits. Some of them were 18- to 20-feet deep—cement pits with lights in 

them, and the control loops on slitters. If we had to go down there and change the lights, 

we had to get Safety to come over and do air sampling for chemicals or whatever. Then 

you would have to wear a harness... 

Mr. McCloskey: So, the only reason to call Safety would be if you were going down into a 

deep pit. But if you were going to be cutting concrete to access some soil, you were not 

going to call Safety unless you were going to go down into a deep pit where you had to 

do air monitoring? [ORAUT 2017, PDF pp. 7–8] 

The exchange above implies M&C would impose confined space controls at times, but did not 

consider concrete penetrations and subsurface work to be a confined space entry. 

Worker #7: We would have somebody come in and cut two lines in the floor, and then 

would jackhammer it out, dig a trench, lay some pipes, cover them over, put sand in and 

compact it, and then re-cement it. [ORAUT 2017, PDF p. 8] 

Mr. Darnell: So, the process was that you would go and get the snake first... 

Worker #7: Yes.

Mr. Darnell: ... and then the power snake. 

Worker #7: Yes.

Mr. Darnell: Would the next step be to cut the cement, and going in with the power 

snake?

Worker #7: Well, after Facilities and R&M, it would be Facilities going in and doing 

whatever they had to do to fix it. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 13 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Mr. Darnell: How often would you get to that third stage? Did the first two stages took 

care of it 50% of the time, or 60% of the time, or...? 

Worker #7: Probably more than that, but there were times when they had to get the floor 

up and replace pipes. [ORAUT 2017, PDF p. 9] 

Mr. McCloskey: So, the lines coming down from the roof are mostly 4-inch cast iron. We 

have heard that the lines underneath the floor servicing the floor drains are vitreous clay. 

Worker #7: I’m not sure what they are under there, because I’ve never dug them up. I 

have never cut them out. That was somebody else’s problem. 

Dr. Mauro: When that happened, was that a relatively rare occasion, maybe once a year

when someone had to go down and do that special job? 

Worker #7: Probably. 

Mr. McCloskey: If we looked at the floor of Building 10 in 1990, how many sections of 

floor would we see that were cut out? 

Worker #7: The whole Beckett Line was cut out. That’s right here. 

Mr. McCloskey: It was cut out so you could install new equipment, not so you could clear 

out drains. So, you cut out the concrete. What do you do after you cut out the concrete? 

Worker #7: You dig down to whatever level you needed because that was all trenches 

installed behind the Beckett. All of the piping was put in the floor. Then there were a 

couple of tanks put in for the annealing solution that pumped in the solution. 

Mr. McCloskey: How big were the tanks?

Worker #7: I would say they were 6 feet by 6 feet by 6 or 8 feet deep. [ORAUT 2017, 

PDF p. 13] 

Worker #7: When the Beckett was installed, the ground was probably open for six 

months. I was [redacted], so I’m going to say that was around 1983 or 1984. 

Mr. McCloskey: Would that have been six months active work with people in the hole? 

Would you be waiting for equipment to arrive? 

Worker #7: From the time you cut out the concrete, dig out the trenches, form everything 

up, and relocate whatever pipes you hit—and you hit stuff because the trench ran the 

whole length of the machine... 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 14 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Dr. Mauro: How big was that? 

Worker #7: From the spooler back, it was five bays. I’ll say 100 feet. [ORAUT 2017, 

PDF p. 13] 

This appears to be where SC&A stopped and took their information; however, reading further, 

the transcript includes the following excerpts: 

Dr. Mauro: So, you’re opening up a place in the floor that’s 100 feet wide. How wide? 

Worker #7: It varied. They only cut 6 feet wide where the tank was, and then there’s 

probably a 4-foot wide trench there. So, to form it they probably had to go out 12 feet to 

form it.

Dr. Mauro: And how deep? 

Worker # 7: Well, they probably went down 10 feet for the tank. Then they had to put in 

clean soil and compact it, and build it up from there. 

Dr. Mauro: Would they have done that with a shovel? 

Worker #7: No, with a backhoe. 

Dr. Mauro: So, you had a backhoe that would reach down into the dirt. What did they do 

with the old dirt?

Worker #7: They took it away. 

Dr. Mauro: Was there a place where they dumped it?

Worker #12: I have no idea. They had a contractor come in. I think that it was Swanson 

Construction, because [redacted] worked for them. 

Mr. McCloskey: Did they bust concrete too, and then excavate? 

Worker #7: That went out for bids. Swanson Construction cut the concrete and dug that 

up. 

Mr. Darnell: Did you ever hear of a company called Cut-Rite?

Worker #7: They used to come in all of the time to cut the floors. Swanson could have 

Cut-Rite come in and cut the floors. Cut-Rite was onsite all the time for us. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 15 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Mr. McCloskey: We have heard that the water table was pretty high around there. The 

hole for the Beckett installation was pretty deep. Did they encounter water during that 

dig? 

Worker #7: Sometimes, they put pumps in to keep the water down while they were 

working. 

Dr. Mauro: This information about digging is important to us. I’m a radiation guy. I can 

visualize that there’s a guy going down there to do what he has to do; and sometimes, 

they kick up dust. If it’s wet, there’s not going to be too much dust coming up. But, if it’s 

dry, then the guy can inhale it. Do you remember, or can you visualize these guys 

wearing dust masks or deliberately wetting down the soil to keep the dust down? When 

the backhoe brought it up, was it dusty or was it so wet that there wasn’t a problem? 

Mr. McCloskey: Did they have to relocate people from that area? 

Worker #7: When they saw-cut, that’s a wet process any way. So it’s wet, but you end up 

with that powdery residue when it dries. 

Ms. Gogliotti: You talked about jackhammering too. Didn’t you? 

Worker #7: That was for small trenches, but when they take out big sections of floor 

square, they square it. They cut all four sides, and then heavy equipment lifts it and carts 

it off. [ORAUT 2017, PDF p. 14] 

Note: Maintenance workers only jackhammered for small jobs. 

Dr. Mauro: This question is about the excavation, and about all of the people who 

worked for M&C and Texas Instruments who were reporting to you. Did a lot of them 

spend a lot of time in the hole—in the ground? 

Worker #7: It depends. We did our own electrical work. We contracted the digging. They 

went in and did the digging, and then we did the electrical. If it was a union job, then we 

couldn’t go in the hole. 

Dr. Mauro: In any given year, did you have any guys who spent 3, 4, or 5 months in a 

hole?

Worker #7: No, maybe a week. Out of the year, you dig up this and that. Most of the 

time, we were putting the pipes in, throwing sand over them, and secure them. Then the 

contractor would come back, fill it in or compact it, and build it up from there. 

Worker #7: If we couldn’t get it out with a snake, it would wait until the next day and 

Facilities would do it. Once I was in [redacted], if it was during the day, by then there 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 16 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

was an R&M and Facilities, so if it was a floor drain problem, they would automatically 

call Facilities. [ORAUT 2017, PDF p. 18] 

Dr. Mauro: Were there people who worked there that spent more than one week per 

year in a hole?

Worker #7: Probably, especially in facilities. 

Dr. Mauro: Do you have a feel for how long? 

Worker #7: When we installed equipment, a lot of the services had to be in the floor 

because of the overhead cranes. Most of the time when we were in a hole in dirt, it was 

because we were installing something. 

Dr. Mauro: Could some people have been down in there for a month, or maybe two 

months per year?

Worker #7: I would think that a month to repair a floor drain would be unacceptable. 

Dr. Mauro: The reason that we ask these things is that these were people who would 

have had more potential for radiological exposure. The more time that someone spends 

down in a hole kicking up dirt working in that situation, the more inhalation there will be. 

The take away that I am getting is that there probably people who spent a lot of time 

working down in the dirt, but it probably wasn’t more than two months. There may 

have been 200 or 300 hours when he may have been working inside a hole, but 

probably wasn’t the rest of the time. [ORAUT 2017, PDF pp. 18–19] 

Worker #7: As far as the soils, most of our involvement was when we were installing 

equipment. We would dig the foundations. When we did PT4, we started that up in 1978 

between Buildings 10 and 4. That was an addition. I was running [redacted] then. We 

worked out there for a year, but it was mostly on concrete. (Sounds like) West Bar 

Construction did the building. We did the foundation. 

Mr. McCloskey: So, the dig lasted a long time, but that was done by contractors. By the 

time you did your install, you were on concrete. 

Worker #7: Yes. They had to put the foundation in for the building. They had to do the 

foundations for the equipment, and then they had to bring the equipment in to install it 

before they built the building around it because it was too big to fit through a door. 

That’s the way that it was done. 

Mr. McCloskey: So, that was a long, drawn out process. Do you remember any issues 

with it?
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 17 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Worker #7: No. That was all typical stuff for us. Dig a big hole, put in the floor drains, 

pour the concrete, everything. [ORAUT 2017, PDF p. 20] 

The main points from the worker interview include the following: 

• Maintenance workers using a snake while standing on the undisturbed concrete floor, 

addressed probably more than 60% of clogged drains (i.e., primary source term). 

• “Stage 3” excavations, (i.e., when the snake did not work), happened approximately once 

a year. 

• Contractors, not maintenance personnel, cut the concrete using a wet process and 

excavated the hole for the Beckett Wire machine with a backhoe. 

• A pump was needed to remove the water from the wet subsurface environment. 

• Once excavated, the contractors lined the hole with clean dirt, and M&C workers 

installed the equipment on top of the clean fill. 

• Of the various M&C groups, Facilities personnel spent the most time performing 

subsurface work, which amounted to less than two months per year. 

SC&A Comment – Confined Spaces Standard

SC&A previously supplied a confined space definition: 

OSHA defines confined spaces and cites examples including pits, tanks, silos, 

maintenance holes, sewers, enclosed drains, and manholes (NIOSH, 2022b). OSHA notes 

that pits, although typically open on top, can be completely underground or below grade 

and can still be a confined space (OSHA, 2015). Supporting industry literature following 

promulgation of the Subpart AA standard noted that confined spaces “include tight work 

areas with reduced air flow” where work such as “welding, cutting, grinding, sanding or 

any high-energy activity can create . . . respirable particles and/or toxic aerosols (Chase, 

2019).” [SC&A 2022, PDF p. 33]

NIOSH Response – Confined Spaces Standard 

Although there were confined spaces at M&C, the concern within the EEOICPA program is only 

for those with a radiological hazard. The source term of primary concern at M&C was the drain

lines in the subsurface of Building 10. The Weston [1996b] drainage system characterization 

describes that system as follows:

Buildings 4 and 10 drainage systems consist of 4-inch vitreous clay (VC) and 4, 5, and 6-

inch cast-iron (CI) lines (referred to as “arterial lines”) located 2 to 3 feet below facility 

Grade. [PDF p. 7]
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 18 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Considering the Weston [1996b] statement above, NIOSH does not consider a Facilities worker 

spending two months during a particular year working on a drain line in such a shallow hole to 

have performed that work in a confined space. 

For the remaining 40% of the time when the snake would not work, workers had to dig ~3 feet to 

access the clogged pipe. A safety professional would not control this work as a confined space 

entry, especially in an industrial facility with active ventilation. The hole is too shallow to 

“include tight work areas with reduced air flow” as the reference SC&A provided above states. 

Furthermore, as pointed out in the SNM License Termination Radiological Dose Assessment, 

“Scenario assumptions for ventilation and work times understate the true dilution effects of 

ventilation” [Weston 1997b, PDF p. 14]. M&C had two exhaust fans that ventilated and removed 

air from Building 10. One ventilation stack equipped with a high-efficiency filter exhausted air 

from the press room at a rate of 616 ft3 per minute (cfm), and another stack exhausted air from 

the furnace area at a rate of 500 cfm [Texas Instruments 1979, PDF p. 20]. 

Within the OSHA confined space standard, there are no strict definitions as to the exact depth 

required to designate, which allows room for professional judgment. However, standard practice 

indicates that safety professionals would not control a 3.5-foot-deep trench dug to service a drain 

line as a confined space. In general, work on the drainage system, identified as the worst-case 

exposure scenario for maintenance workers, would not have been performed within a confined 

space work environment. 

SC&A Comment – Confined Spaces and Work Not Associated with Drain Line Cleaning

While the 1995 drain line sediment reading is a high concentration level, can it be 

applied as a bounding exposure for unrelated inside subsurface work (i.e., non-drain line 

cleaning) for which little, if any, information is available and for which confined space 

atmospheres were involved? [SC&A 2022, PDF p. 22] 

NIOSH Response – Confined Spaces and Work Not Associated with Drain Line Cleaning

NIOSH acknowledges there were confined spaces at M&C. However, the key consideration is 

whether there were contaminated confined spaces associated with the Building 10 subsurface 

where M&C workers incurred exposures that represent a plausible scenario for which NIOSH 

cannot bound doses. NIOSH finds:

• The pathway for contaminants to get to the subsurface was through the floor drains, and 

to a lesser extent, through cracks in the concrete when the floor flooded, and 

contaminants got washed into the subsurface. 

• The subsurface is well described and shows that after contaminants flowed to the 

subsurface, they generally stayed within 5 feet of the drainage system network of pipes, 

which were approximately 3-feet deep.
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 19 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Interviewees described subsurface work that included some confined space work; however, their 

recollections included work in other buildings and areas not associated with the source term. 

When workers did describe work in Building 10, they referred to the entire building and did not 

differentiate whether their work was in the part of the building that contained the source term of 

primary concern: Priority 1 drain lines. This is an important distinction because nuclear 

manufacturing operations were primarily performed in the northern third of Building 10, and 

support activities, including transportation and storage, were performed in the balance [Weston 

1996a, PDF p. 10].

To elaborate, the area of Building 10 with the Priority 1 drain lines is small compared to the rest 

of the building. Although all of Building 10 was resurveyed in 1995, Figure 1 shows the portion 

that M&C determined would require further remediation. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 20 of 39

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Figure 1: Building 10 – Affected Areas [Weston 1996a, PDF p. 15].

Note: The scale indicates 1 inch = 40 feet in the original Weston [1996a] document.

This, 1/3 northwest portion of Building 10, is enlarged to show the location of the source term, 

Areas 1–12 and 18. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 21 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Figure 2: Building 10 Pipe Grouping for Uranium-235 Inventory Development [Weston 1996b, PDF p. 27].

Note: ~1/8 inch represents 5 feet in the original Weston [1996b] document and is the extent of 

contamination migration from any drain line.

When M&C did work in the northwest third of Building 10, considering that Priority 1 data 

dominate NIOSH’s bounding model and that contamination did not migrate far into the 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 22 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

subsurface environment, it should be noted that not all Building 10 work was associated with the 

higher contamination levels NIOSH uses to calculate a bounding model. The following excerpt 

describes contamination migration: 

Based on observations during the 1996 remediation project, some wash water went into 

the Building I0 floor drains. Some portion of the water that entered the drains apparently 

leaked from the pipes depositing uranium in the surrounding soils. However, the uranium 

did not get into the ground water. Its travel in the ground had extended only about 5 feet 

from the pipes through the soil when it was excavated during site remediation. Tl 

measured this in 1996. This observation is explained by the geochemistry of uranium (see 

below). Tl excavated the uranium contaminated soil in 1996. Where acid is known to 

have been used to decontaminate non-nuclear materials (e.g., west side of Building 5), 

excavation also found that the uranium had traveled only a limited distance in the soil. 

[Elliott 1997, PDF p. 40–41]

Whenever M&C workers accessed areas beyond 5 feet of the source term used in NIOSH’s 

bounding model, they would have incurred exposures described in the following excerpts from

SNM License Termination Hypothetical Radiological Dose and Exposure Rate Assessment 

Priority 2 Drain Lines [Weston 1997a] and SNM License Termination Radiological Dose 

Assessment [Weston 1997b]. 

The purpose of this dose and exposure rate assessment is to consider the potential 

radiological dose and gamma exposure to a hypothetical receptor as a result of 

exhuming Priority 2 drain lines at the Texas Instruments Incorporated (TI), Attleboro 

Facility. [Weston 1997a, PDF p. 4]

The source term for this report is defined as the total inventory of radioactive material

contained within the area occupied by exhumed Priority 2 drain lines. The source term 

was calculated based on radionuclide concentrations of residuals within the volume of 

the drain lines in place before hydrolasing decontamination (used for the predecontamination scenario)...[Weston 1997a, PDF p. 4]

All possible environmental transport pathways for this dose assessment were used to 

perform the Priority 2 drain lines pre- and post-decontamination dose assessments. Predecontamination concentrations of residual total uranium in the drain lines were used to 

provide an upper bound for the exercise. Use of the concept of "bounding scenarios" 

provided streamlined final output dose assessment data and conclusions that can be used 

to support decision-making. When evaluating potential scenarios, it became evident that 

postulated doses from the Priority 2 pipes would be significantly higher than the Priority 

3 drain lines. Analysis of potential doses from Priority 3 drain lines would result in 

significantly lower doses and is therefore unnecessary because the pre-decontamination 

scenario for Priority 2 drain would result in significantly higher doses. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 23 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

In developing the methodology for this hypothetical dose assessment, both current- and 

future-use exposure scenarios were evaluated. The current-use and future-use scenario 

analyses accounted for all potential uses for the hypothetical drain line source area, 

given that there was absolutely no corporate control of the TI site. The analysis identifies 

the activity with the highest dose potential as exhuming the entire lot of Priority 2 drain 

lines during a one-time maintenance activity. [Weston 1997a, PDF p. 5]

The TEDE resulting from the proposed hypothetical scenario prior to decontamination of 

drain lines which represents the upper bound case is estimated to be 0.71 mrem in the 

first year after exposure. The inhalation pathway contributed 0.41 mrem, approximately 

57% of the TEDE. Ingestion and direct gamma doses contributed 41%, combined.

[Weston 1997a, PDF p. 7]

During typical drain line maintenance in unaffected areas of the facility, workers are not 

significantly exposed to pipe interiors. Common handling involved removal and disposal 

of complete sections, or breakage to reduce volume. [Weston 1997a, PDF p. 11]

Maintenance worker intrusion into any of the five source areas was selected as the 

bounding scenario for dose assessment. Further, the Building 4, 5, and 10 residual areas 

were selected as having the highest localized uranium concentrations and highest 

likelihood of worker intrusion resulting from building maintenance operations This 

scenario location was selected because intrusion would allow multiple exposure 

pathways including direct exposure to gamma radiation, inhalation of resuspended dust, 

and ingestion of contaminated soils...Under the current exposure scenario, Tl 

maintenance workers are assumed to excavate into contaminated areas within the 

Buildings 4, 5 and 10 interiors, which contain the highest concentrations of residual 

radioactive materials. Therefore, dose assessment using application of conditions 

associated with the building interiors is assumed to bound potential doses resulting from 

similar activities in any of the other four source areas outside the buildings. In the 

current exposure scenario, maintenance workers excavate a trench 10 m long, 3 m wide, 

and 1.5 m deep. Postulated environmental transport pathways associated with this 

scenario are described in Table 3. This maintenance is assumed to be performed twice 

per year. [Table 3 omitted] Postulated future uses of the site included continued 

performance of manufacturing operations in an industrial setting...[Weston 1997b, PDF 

pp. 13–14]

To summarize, M&C evaluated exposures to maintenance workers using pre-D&D survey data, 

developed a bounding scenario for all work activities except those associated with Priority 1 

drain lines, and calculated a dose of <1 mrem. Conservatively, NIOSH applies its model to all 

subsurface work at M&C, including work in most of Building 10 that was not associated with the 

Priority 1 drains. 
Response Paper NIOSH Response to “SC&A Review [April 2023] of 

NIOSH Response [January 2023] to SC&A’s Supplemental 

Review of M&C Work Group Issues [August 2022]”

August 22, 2023

Page 24 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Regarding SC&A’s concern about other types of work, when M&C did perform other work, such 

as replacing large pieces of machinery, they (or contractors) dug deeper holes. There is some 

potential that contaminants migrated into some of those soils, especially if they were close to a 

drain line. However, NIOSH does not consider that work extensive enough to be selected as the 

plausible bounding scenario. 

SC&A/Work Group Comment – Applying Mound Surrogate Data to Dust Loading Factor 

NIOSH does not respond to the central question posed: In applying the Mound surrogate 

data to derive a dust loading factor, did they address confined space considerations? 

From a larger perspective, did they consider the impact of confined spaces on their 

modeled airborne resuspension of uranium and thorium? The answer appears to be “no” 

in both cases. Confined spaces represent a new issue that has not been addressed.

[SC&A 2023, PDF pp. 9–10] 

...M&C maintenance workers doing subsurface work routinely had to snake out and 

repair (cut, saw, grind, weld) underground pipes. These routine components of M&C 

operations also created additional sources of radioactive dusts and particulates, beyond 

those from the (Mound-based) dust-loading. The current NIOSH bounding model does 

not appear to account for these and should. [ABRWH 2023a, PDF p. 20] 

NIOSH Response – Applying Mound Surrogate Data to Dust Loading Factor 

The hazards associated with working in confined spaces are not new to the field of industrial 

hygiene and were also recognized by M&C personnel. NIOSH is committed to reviewing recent 

suggestions to upgrade its dust loading models, including enhancement factors and confined 

spaces, and will consider incorporating methods suggested by SC&A in their supplemental 

review. In addition, as discussed by SC&A in SC&A Commentary on NIOSH’s Approach to 

Quantifying Outdoor and Indoor Airborne Dust Loadings, airborne contamination levels can be 

modeled (i.e., bounded) up to a choking level [SC&A 2021, PDF p. 22], making the confined 

space effect on dust loading factors a TBD issue and not an SEC issue. This addresses SC&A’s 

remaining issue with applying the Mound surrogate data to derive a dust loading factor. 

ADDITIONAL INTRUSIVE ACTIVITY INFORMATION FOR TABLE 1, 

COMPARISON OF AWE SITES

In the Supplemental Review of M&C Work Group Issues [SC&A 2022], SC&A provided a table 

with the following five column headings: (1) AWE site, (2) source of exposure potential, (3)

intrusive work activity (covered), (4) SEC class designated, (5) and reference. During the May 

12, 2023, M&C Work Group meeting, NIOSH indicated it would provide information that could 

serve to update Table 1 with additional detail concerning intrusive activities and dose potential. 

The following table completes that action.
Response Paper NIOSH Response to “SC&A Review [April 2023] of NIOSH 

Response [January 2023] to SC&A’s Supplemental Review of 

M&C Work Group Issues [August 2022]”

August 22, 2023

Page 25 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Table 2: Additional Information to Augment SC&A’s Comparison of AWE Sites Table 1

AWE Site Available Data for Residual 

Period Intrusive Work Activities in the Residual Period

First Year 

Residual Period – 

Radionuclide(s) of 

Concern

First Year 

Residual Period – 

Internal Dose 

(mrem CED) 

Carborundum

(Residual period 

NOT added to the 

SEC)

Battelle-TBD-6000 default 

values and air data from the 

preceding operational periods

Lathe and diamond wheel grinding plant:

“Very dusty and dirty environment. You always had to 

wash your face and hands at the end of the day. People 

wore dust masks and maintenance people wore blue 

uniforms” [ORAUT 2015, PDF pp. 4–5]. 

Uranium 3483

Baker Brothers

(Residual period 

NOT added to the 

SEC)

First residual period: BattelleTBD-6000 default values at the 

start and air data near the end of 

the period

Second residual period: air data 

during the preceding 

remediation period

General machine shop maintenance [NIOSH 2012] Uranium 229

Hooker 

Electrochemical

(Residual period 

NOT added to the 

SEC)

Air data during the preceding 

operational period and 

surrogate air data

Construction and maintenance of 10" water line, 42" 

river water line, and outfall sewer line - portions both on 

and off AEC Property. Maintenance of the contractor’s 

plant, CC2 laboratory, BNP plant, storage area, 

combined shops, locomotive shed, garage, men's change 

house, office building, general storehouse, material 

shed, and parking garage. Position descriptions for the 

contract include operation department superintendents 

who would oversee the maintenance of the chemical 

plant [AEC 1953; Hooker 1953, PDF pp. 2–3; Fry 1953; 

Hooker 1957; AEC 1958]

Uranium 13
Response Paper NIOSH Response to “SC&A Review [April 2023] of NIOSH 

Response [January 2023] to SC&A’s Supplemental Review of 

M&C Work Group Issues [August 2022]”

August 22, 2023

Page 26 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

AWE Site Available Data for Residual 

Period Intrusive Work Activities in the Residual Period

First Year 

Residual Period – 

Radionuclide(s) of 

Concern

First Year 

Residual Period – 

Internal Dose 

(mrem CED) 

Chapman Valve

(Residual period 

NOT added to the 

SEC)

Contamination and soil data 

toward the end of the residual 

period and back projected

Worker types included: mechanics, heat treaters, 

steamfitters, machine repairers, steam fitters, plumbing 

and general maintenance, electricians, milling machine 

operators, centerless grinder operators, portable grinder 

machinists, chipper machinists, assemblers, tool crib 

machinists, turret lathe operators, janitors, 

decontamination workers, firefighters, and general 

foremen [NIOSH 2006]

Uranium 8 

Bliss & Laughlin

(Residual period 

NOT added to the 

SEC)

Air data from the preceding 

operational period

The trench was cleaned, scabbled, jack-hammered, and 

sand-blasted. Ceiling trusses and perpendicular 

members were decontaminated. The concrete pad over 

trenches and pits was removed and the trench was 

remediated (max 1420 pCi/g) [USACE [1999, PDF pp. 

9–14]

Uranium 24

Simonds Saw

(Residual period 

NOT added to the 

SEC)

Air data from the preceding 

operational period and the 

residual period

Steel-mill maintenance activities [NIOSH 2010a] Uranium, Thorium 4518+

1.09 WLM 

(Radon)

Blockson

(Residual period 

NOT added to the 

SEC)

Bioassay from the preceding 

operational period; radiation 

and air data from the residual 

period

Maintenance work on the filtration and duct system 

[NRC 1984, PDF p.12] 

Uranium, Thorium 778+a

0.1 WLM (Radon)
Response Paper NIOSH Response to “SC&A Review [April 2023] of NIOSH 

Response [January 2023] to SC&A’s Supplemental Review of 

M&C Work Group Issues [August 2022]”

August 22, 2023

Page 27 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

AWE Site Available Data for Residual 

Period Intrusive Work Activities in the Residual Period

First Year 

Residual Period – 

Radionuclide(s) of 

Concern

First Year 

Residual Period – 

Internal Dose 

(mrem CED) 

Dow Chemical 

(Madison)

(Residual period 

NOT added to the 

SEC)

Air data from the preceding 

operational period and the 

residual period

Metal sanded in the rolling mill, billets scalped, and 

scrap handling [Simmons Cooper 2007, PDF p. 7]

Uranium, Thorium 8204+

0.39 WLM 

(Radon)

General Steel

(Residual period 

NOT added to the 

SEC)

Surrogate air data Activities listed include the following: pipefitter, 

electrician, laborer, pattern shop sweeper, utility man, 

tunnel laborer, carpenter, iron worker, roofer, concrete 

finisher, janitor, gardener, and Production &

Maintenance Department-clerks [GSI 1967, PDF pp. 3-

165] 

Uranium 60a

Wah Chang

(Residual period 

NOT added to the 

SEC)

Air data from the preceding 

operational period

Excavation and removal of 100,000 yd3 contaminated 

surface and subsurface sediments exceeding the gamma 

radiation action level [Gaines 1997, PDF p.13] 

Uranium 0.04

United Nuclear

(Residual period 

NOT added to the 

SEC)

Air data from the preceding 

operational period and the 

residual period

General nuclear production facility maintenance 

[NIOSH 2010b]

Uranium 103

Norton

(Residual period 

NOT added to the 

SEC)

Air data from the operational 

(pre-1958) and residual (1963–

2009) periods

1963–2009: General nuclear production facility 

maintenance [NIOSH 2011a,b]

Uranium, Thorium 342+

0.10 WLM 

(Radon)
Response Paper NIOSH Response to “SC&A Review [April 2023] of NIOSH 

Response [January 2023] to SC&A’s Supplemental Review of 

M&C Work Group Issues [August 2022]”

August 22, 2023

Page 28 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

AWE Site Available Data for Residual 

Period Intrusive Work Activities in the Residual Period

First Year 

Residual Period – 

Radionuclide(s) of 

Concern

First Year 

Residual Period – 

Internal Dose 

(mrem CED) 

Norton

(Residual period 

added to the SEC)

Bioassay and air data for the 

periods before and after the 

1958–1962 part of the residual 

period that is insufficient to 

bound potential internal 

exposures during these 

operations

1958–1962: Refractory kilns and furnaces dismantled 

brick-by-brick and transferred to barrels. Equipment and 

materials solvent-washed, dried with paper towels, 

dismantled, and transferred to barrels. Surface areas of 

the building were cleaned and residue was placed in 

barrels. Materials removed included: bricks, batts, dustcollecting ventilation ducts, and pipes. There were 287 

barrels (~19 tons) of waste, including 15 pounds of

thorium and 25 pounds of uranium [NIOSH 2011a,b].

N/A N/A

Linde

(Residual period 

NOT added to the 

SEC)

Contamination data from 2001 1970–2006: Subsurface utility tunnel maintenance 

activities [NIOSH 2011c]

Radium, Thorium, 

Uranium

35256+

3.94 WLM 

(Radon)

Linde

(Residual period 

added to the SEC)

Air data from one building in 

1969 

1954–1969. Renovations, including jack-hammering the 

primary process building. NIOSH also proposed to use 

the same data to bound all exposures in the other five 

buildings and outside areas [NIOSH 2011c].

Radium, Thorium, 

Uranium

5479

Vitro

(Residual period 

NOT added to the 

SEC)

Air data from 1977 October 1, 1965–1985: Manufacturing plant facility 

maintenance [NIOSH 2011d; NIOSH 2015]

Lead, Uranium 88a

9.16 WLM 

(Radon)
Response Paper NIOSH Response to “SC&A Review [April 2023] of NIOSH 

Response [January 2023] to SC&A’s Supplemental Review of 

M&C Work Group Issues [August 2022]”

August 22, 2023

Page 29 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

AWE Site Available Data for Residual 

Period Intrusive Work Activities in the Residual Period

First Year 

Residual Period – 

Radionuclide(s) of 

Concern

First Year 

Residual Period – 

Internal Dose 

(mrem CED) 

Vitro

(Residual period 

added to the SEC)

None 1960–October 1, 1965: D&D of the Process building. 

Movement and burial with bulldozers of two residue 

stockpiles (leftover from uranium ore processing). One 

pile was 4,268 dry tons and the second was 85 tons. 

NIOSH did not find a description of shutdown or D&D 

activities, nor were interviewees able to provide any 

detailed information [NIOSH 2011d; NIOSH 2015]

N/A N/A

M&C Contamination data from the 

preceding operational period 

and pre-D&D characterization 

soil and contamination data

General nuclear production facility maintenance: 

Subsurface work: 17% occupancy, with a 2x TIB 70 

resuspension factor applied. 

Roof and ceiling work: 8% occupancy, with a vigorous 

work resuspension factor applied. 

Welding work: 2% occupancy, with a 10x vigorous 

work resuspension factor applied. 

HVAC work: <<1% occupancy, with a barely tolerable 

resuspension factor applied. 

Remaining work: 73% occupancy, with a 10x TIB 70 

resuspension factor applied. 

Uranium, Thorium 71

a Dose prorated to reflect the full year.

NIOSH has included information in Table 2 that provides context regarding the intrusive types of work performed at the other AWE 

sites where the Advisory Board agreed with NIOSH’s ability to bound exposures during residual period work. The precedents set by 

the Advisory Board in their SEC deliberations are essential because they provide consistency and fairness in implementing the 

EEOICPA Program.
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 30 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

M&C WORK GROUP CONCERNS

Work Group Concern – Data Applicability

The following excerpts show data applicability concerns that have been presented at an Advisory 

Board meeting and M&C Work Group meeting: 

NIOSH applies 1995 D&D survey data as basis for an upper bound for residual period 

exposure. For radiological data from one time period to be considered informative about 

exposures during another time period, there should be sufficient similarity of conditions 

and processes between the two periods. [ABRWH 2023b, PDF p. 20] 

M&C maintenance workers were given no radiological health and safety (H&S) 

information or training during the residual period, and only occasionally received 

personal protective equipment (PPE). Also, after 1983, following the NRC’s removal of 

radiation work restrictions for Building10, they believed they were not working under 

hazardous radiological conditions. 

Thus, certainly after 1983, M&C maintenance workers could not be expected to have 

followed the ordinary, common-sense precautions that any intelligent person would 

follow when working on and near the piping in a potentially hazardous radiation 

environment. 

The Result: The M&C maintenance workers would be expected to experience greater 

doses of radiation than assessed in the NIOSH bounding model. [ABRWH 2023a, PDF p. 

11] 

NIOSH Response – Data Applicability

If NIOSH identified air monitoring during an operation (e.g., grinding) in one time period and 

tried to apply that data to a different time period and operation (e.g., welding), then the Work 

Group’s concern could be valid. Similarly, if NIOSH used Priority 3 drain line data to bound 

exposures during work with the Priority 1 source term, then again, the Work Group would have 

a valid data applicability argument. On the contrary, NIOSH validated a bounding source term 

(pre-D&D to the extent a fuel pin was still present) and applied appropriate resuspension/dust 

loads for the various operations described by interviewees. 

Furthermore, one of the primary reasons the Weston [1996b] drainage system characterization 

(the report where NIOSH obtained the subsurface data) was performed before D&D in 1995, was 

to quantify the risk to ongoing drain line maintenance workers as documented in the following 

excerpt: 

The drainage system investigation was performed immediately after the Pilot-Scale 

Interiors Remediation Project and prior to the Full-Scale Interiors Remediation Project. 

An aggressive investigation schedule was implemented in support of Nuclear Regulatory 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 31 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Commission (NRC) license termination and to assess the potential for inadvertent 

exposures to non-radiological workers performing routine· drainage system 

maintenance. [Weston 1996b, PDF p. 7] 

The excerpt above confirms that drain line maintenance was still being performed at the time of 

the 1995 survey. In fact, after these data were obtained, and because of the results, M&C 

implemented controls on future drain line maintenance using three levels of priority designation 

[Weston 1996b, PDF p. 29]. 

Although the frequency of clogged drains may have increased over time as the building aged, the 

techniques employed to unclog drains did not change throughout the residual period (i.e., snake 

technology did not change significantly from 1968 to 1995). 

Work Group Concern – Worker Protection

An August 16, 2023 M&C Work Group presentation stated that “maintenance workers were 

unaware of radioactive contamination and operated without radiological controls and health 

physics oversight” [ABRWH 2023b, PDF p. 8]. 

NIOSH Response – Worker Protection

Work practices such as those specified in the Work Group’s concern do not affect the source 

term or any of the “three legs of the stool” that form NIOSH’s bounding method because the 

M&C model does not assume any worker training or the use of engineering and administrative 

controls. 

Work Group Concern – Claimant Favorable Assumptions

An August 16, 2023, presentation states [ABRWH 2023b]:

How does M&C compare with other AWEs? 

• SC&A finds M&C to be comparable to facilities with more intrusive activities, e.g., 

those related to renovation as defined by NRC and found at Linde Ceramics (SEC 

class designee). 

• Why is this important? 

o Standard models from OTIB-0070 and TBD-6000 assume more passive worker 

activities related to occupancy, like other non-SEC AWEs. [PDF p. 10] 

NIOSH use of “extreme conservatism” to account for M&C’s “intrusive activities, high 

exposure conditions, uncertain facility activities, or unknown contamination sources” 

(NIOSH, 2023a) results in a high bounding value –but is it plausible? [PDF p. 13] 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 32 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response – Claimant Favorable Assumptions 

The information presented at the August 16, 2023, Advisory Board meeting is inaccurate, 

especially regarding OTIB-0070. It could be argued that TBD-6000 allows default assumptions 

which may be considered more passive, but OTIB-0070 makes no such assumptions and requires 

the user to make a thoughtful selection. It is a document that provides options to select models 

that are as aggressive or passive as appropriate. 

SC&A and the Work Group are misinterpreting NIOSH’s use of the phrase “extreme 

conservatism” to mean implausibly high. NIOSH is using conservative assumptions that are 

appropriate for a bounding scenario. The maximum predicted committed effective dose 

equivalent is still only 71 mrem which is not implausibly high and is on par with normal 

background radiation levels every American experiences. 

Work Group Concern – AWE Equipment

An August 16, 2023, presentation states [ABRWH 2023b]:

What were typical intrusive activities and exposure pathways during M&C residual 

period? 

• Maintenance, movement, and replacement of repurposed AWE equipment [PDF p. 

11]

NIOSH Response – AWE Equipment

NIOSH has previously responded to this concern. Texas Instruments reported to the NRC that 

the AWE operations (Buildings 3, 4, and 10) were decontaminated and decommissioned and that 

all radioactive materials were removed during the period from 1955 to 1968; the largest Building 

10 cleanup effort occurred at the end of 1958. “...contaminated noncombustible scrap material 

and machinery were collected in 55-gallon steel drums and disposed of through authorized 

agencies or buried on-site in compliance with 10CFR20.304” [Sowell 1985, PDF p. 12]. 

Work Group Concern – Burial Area

An August 16, 2023, presentation states [ABRWH 2023b]:

What were typical intrusive activities and exposure pathways during M&C residual 

period? 

• Excavating contaminated soils, including those near or within radioactive waste 

burial sites [PDF p. 11] 

NIOSH Response – Burial Area

NIOSH developed a model to bound exposure during subsurface work in areas outside of 

Building 10 including the burial ground. However, during Work Group discussions NIOSH 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 33 of 39

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

agreed to assign doses from the Building 10 subsurface model to all workers since workers 

constantly moved about the site and because those doses were more claimant favorable. In 

addition, at the July 13, 2023, M&C Work Group meeting, the Work Group conceded other 

exposures including those from the burial ground with the following statement:

Attention to subsurface exposures in Building 10. NOTE: The Work Group (WG) and 

staff generally agreed that the greatest exposures to the M&C maintenance workers came 

from the subsurface work in Building 10. Since the NIOSH bounding model is applied to 

all claimants, further discussion during this presentation focuses solely on such 

subsurface work and whether or not it is bounded. [ABRWH 2023a, PDF p. 8]

If the Work Group is aware of new technical information related to the burial ground, NIOSH 

requests a copy so we may consider it. 

Work Group Concern – Confined Spaces and Applying Mound Surrogate Data

A July 13, 2023, presentation states [ABRWH 2023a]:

The Mound database: Collected under different conditions than the M&C subsurface 

trenching. 

• The Mound project trenching data were collected outdoors on a country lane, 

whereas the M&C maintenance subsurface exposures, of course, took place indoors 

in Building 10. 

• As such, using the Mound data as surrogates for M&C violates one of the Criteria for 

the Use of Surrogate Data, adopted by the Board in 2014. [PDF p. 17] 

The Mound database seems a poor fit for M&C 

Because of the major differences in work environments between Mound and M&C – an 

outdoor, relatively placid country lane vs. an indoor, dirty, often muddy industrial 

worksite, respectively – this WG member believes the Mound database is a poor fit for 

M&C surrogacy. [PDF p. 18]

NIOSH Response – Confined Spaces and Applying Mound Surrogate Data

The Mound surrogate issue was considered in SC&A Commentary on NIOSH’s Approach to 

Quantifying Outdoor and Indoor Airborne Dust Loadings. For that work, SC&A enlisted the 

services of Lynn R. Anspaugh, Ph.D., Fellow of the University of California, National Science 

Foundation Biophysics and University of California, U.S. Atomic Energy Commission (AEC) 

Radiological Physics. He is Research Professor of Radiobiology Emeritus, University of Utah. 

Dr. Anspaugh is an expert on radiation dosimetry and radiation dose reconstruction. He worked 

33 years at Lawrence Livermore National Laboratory in a number of positions, including 10 

years as Leader of the Environmental Sciences Division. Dr. Anspaugh has been involved in 

dose-reconstruction studies for people exposed to fallout from nuclear weapons tests, the 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 34 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Chernobyl accident, releases from the Mayak Production Association in Russia, and the 

Fukushima accident. Dr. Anspaugh is the author or co-author of 350 papers and reports, most of 

which are related to radiation-dose-reconstruction activities. Dr. Anspaugh has been a consultant 

to the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), the 

International Atomic Energy Agency, and the World Health Organization. He has been a 

member of the U.S. delegation to UNSCEAR since 1987 [NCRP, no date]. 

The following excerpts show what SC&A, with Dr. Anspaugh as a co-author, stated in SC&A 

Commentary on NIOSH’s Approach to Quantifying Outdoor and Indoor Airborne Dust Loadings

[SC&A 2021] about the use of the Mound surrogate data at M&C:

In SC&A [2021, Section 5.2], SC&A considered the use of Mound outdoor dust loading 

values to M&C indoor environments. SC&A cites NUREG/CR-5512, Volume 1 (p. 

6.11), For this analysis, the radioactive concentrations in indoor air for the building 

renovation and residential scenarios have been assumed to be 10-4 and 5 x 10-5 g/m3, 

respectively. This range is a fraction of the maximum total dust limits, representing 

longer-term average concentrations and accounting for airborne dust from 

nonradioactive sources. This range provides a prudently conservative estimate of actual 

radioactive dust-loadings in the workplace or household, and serves as an adequate 

basis for the first-level generic screening analysis. [PDF pp. 18–19] 

SC&A further concludes, The renovation indoor dust loading of 10-4 g/m3

 (100 ug/m3) 

might include excavation and would seem to independently support NIOSH’s use of 212 

ug/m3 as a reasonable estimate when applied to the M&C subsurface indoor excavation 

scenario and also to indoor excavation dust loading in general. Since this is an indoor 

dust loading value, SC&A suggests that NIOSH also refer to NUREG/CR-5512 (in 

addition to the Mound outdoor data) as a basis for the selected dust loading for both 

M&C and for use in OTIB-0070. [SC&A 2021, PDF p. 19] 

NIOSH concurs with SC&A’s recommendation. The favorable comparison with the indoor 

renovation dust loading value recommended in NUREG/CR-5512 provides confidence in 

NIOSH’s 212 ug/m3 dust loading value for M&C, in spite of the differences between the Mound 

and M&C physical environments.

Considering the totality of information compiled in this report, SC&A believes that the 

use of a dust loading of 212 μg/m3 for subsurface work both indoors and outdoors at 

M&C is reasonably compatible with data and information summarized in this report, 

including the data reported from Mound by the interviewed SME. [PDF p. 21] 

While SC&A’s survey and interpretation of the data indicate that the suggested value of 

212 μg/m3 may not necessarily be sufficiently conservative for many excavation 

scenarios, a number of mitigating factors are also present at M&C that should be 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 35 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

considered. First, the soil at M&C was likely moist. Second, the dust loading used for 

dose reconstruction at M&C covered the entire assumed time period of 2 months; i.e., the 

suggested exposure models are not trying to reconstruct short-term exposures, where 

dust loading might peak during active and aggressive excavation, but are making use of 

the dust loading for deriving inhalation exposures over a more protracted period of time. 

[PDF p. 22]

If the Work Group considered the mitigating factors present at M&C referenced above and 

disagrees, NIOSH requests any technical supporting information so we may augment our model. 

CONCLUSION

The Work Group’s concerns [ABRWH 2023b, PDF p. 20] with the back application of the 1995 

drainage system characterization data were a result of Building 10 subsurface work associated 

with the effects of coagulants, the aerosolization of drain line contamination, and work in 

confined spaces. This paper has demonstrated how NIOSH can address each of those concerns 

and that the concerns have no effect on the bounding source term identified by NIOSH and 

previously agreed upon by SC&A. 
Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 36 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

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Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

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Response Paper NIOSH Response to SC&A’s Review of NIOSH 

Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

Page 38 of 39

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

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Response to SC&A’s Supplemental Review of M&C Work 

Group Issues

August 22, 2023

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

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